ACCEPTED
02-16-00386-CR
SECOND COURT OF APPEALS
FORT WORTH, TEXAS
12/21/2017 4:43 PM
DEBRA SPISAK
CLERK
NO. 02-16-00386-CR
FILED IN
IN THE SECOND COURT OF APPEALS 2nd COURT OF APPEALS
FORT WORTH, TEXAS
FORT WORTH, TEXAS
12/21/2017 4:43:20 PM
DEBRA SPISAK
Clerk
CHASE MATHEW KARRENBROCK,
Appellant,
v.
STATE OF TEXAS,
State.
UNOPPOSED THIRD MOTION FOR EXTENSION OF TIME
TO FILE BRIEF FOR APPELLANT
Trial Court Cause No. F15-927-158,
State of Texas v. Chase Mathew Karrenbrock
158th District Court of Denton County, Texas
Hon. Steve Burgess presiding.
CHASE MATHEW KARRENBROCK, Appellant, requests a seven (7) day
extension of time to file his Brief for Appellant. In support of this Motion Appellant
respectfully requests the court to consider the following:
1. Appellant was convicted and sentenced on or about September 29, 2016. His
Brief for Appellant is currently due December 14, 2017.
THIRD MOTION FOR EXTENSION OF TIME TO FILE PAGE 1 OF 4
BRIEF FOR APPELLANT
2. Appellant is incarcerated.
3. Appellant’s attorney has had a series of health issues which necessitated
time away from the office, which would otherwise have been dedicated to
preparing Appellant’s argument.
4. Appellant requests a seven (7) day extension of time to file his Brief for
Appellant, which would make the brief due December 21, 2017.
5. This is the third motion for extension filed by Appellant. This Motion is not
filed for the purposes of delay only, but that justice may be served.
6. As shown in the certificate of conference, the undersigned has conferred
with counsel for the State. The State does not oppose this motion.
PRAYER FOR RELIEF
For the reasons described Appellant, Chase Matthew Karrenbrock requests that
this Court grant his Third Motion for Extension of Time to File Brief for Appellant
and extend the deadline for filing the Brief for Appellant up to and including
December 21, 2017.
Appellant also requests general relief.
Respectfully submitted,
J. Jeffrey Springer
State Bar No. 18966750
jeff@springer-lyle.com
Aubry L. Dameron
State Bar No. 24093766
aubry@springer-lyle.com
THIRD MOTION FOR EXTENSION OF TIME TO FILE PAGE 2 OF 4
BRIEF FOR APPELLANT
SPRINGER & LYLE, LLP
1807 Westminster
Denton, TX 76205
940-387-0404
940-383-7656 (fax)
By: /s/ J. Jeffrey Springer
J. Jeffrey Springer
ATTORNEY FOR APPELLANT
CERTIFICATE OF CONFERENCE
I certify that on December 18, 2017, my office conferred by phone with Matthew J.
Whitten, Esq., Denton County District Attorney Appellate Division, and the State is NOT
opposed to this motion.
/s/ J. Jeffrey Springer
J. Jeffrey Springer
CERTIFICATE OF SERVICE
I certify that on December 21, 2017, I caused to be served the foregoing instrument on
the following counsel of record via the Court’s electronic case filing system pursuant to Tex. R.
App. P. 9.5:
Catherine Luft
DENTON COUNTY DISTRICT ATTORNEY
Chief, Appellate Division
PO Box 2344
Denton, Texas 76202-2344
Catherine.luft@dentoncounty.com
/s/ J. Jeffrey Springer
J. Jeffrey Springer
THIRD MOTION FOR EXTENSION OF TIME TO FILE PAGE 3 OF 4
BRIEF FOR APPELLANT
STATE OF TEXAS §
§ Know all men by these presents:
COUNTY OF DENTON §
Before me, the undersigned notary, personally appeared J. Jeffrey Springer,
who after being sworn upon his oath, deposed and stated:
"My name is J. Jeffrey Springer. I am the attorney for Appellant in the
above-styled and numbered appeal. I am over 18 years of age, competent, and have
never committed a felony or misdemeanor more serious than a traffic violation. I
have read the above and foregoing Third Motion for Extension of Time to File Brief
for Appellant, and the allegations contained in it are within my knowledge and are
true."
Is/ J. Jeffrey Springer
J. Jeffrey Springer
SUBSCRIBED AND SWORN TO before me, the undersigned Notary
Public, by on December 21, 2017, by J. Jeffrey Springer.
WITNESS my hand and official seal.
My commission expires: AJ'YJ.l g1.41\4
.~·~~!':"/:~'''•, BONITA CARTER
{f/.;;S};.. ~1>..~
Notary Public. State or Texas
\~..~. .~.€ My Commission Expires
~-:J.t:?.~::i~l' April 08, 2019
THIRD MOTION FOR EXTENSION OF TIME TO FILE PAGE40F4
BRIEF FOR APPELLANT
Chase Karrenbrock v. State
Combined Opinion